Marian Fraser v. the State of Texas

CourtCourt of Appeals of Texas
DecidedOctober 1, 2024
Docket07-23-00131-CR
StatusPublished

This text of Marian Fraser v. the State of Texas (Marian Fraser v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marian Fraser v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-23-00131-CR

MARIAN FRASER, APPELLANT

V.

THE STATE OF TEXAS, APPELLEE

On Appeal from the 19th District Court McLennan County, Texas Trial Court No. 2014-158-C, Honorable David Hodges, Presiding

October 1, 2024 MEMORANDUM OPINION Before PARKER and DOSS and YARBROUGH, JJ.

This tragic case involves the death of four-month-old C.F.—determined to be

caused by ingestion of diphenhydramine (Benadryl).1

1 This case is before this Court for a third time. See Fraser v. State, 523 S.W.3d 320 (Tex. App.—

Amarillo 2017) (reversing conviction) (Fraser I), rev’d 583 S.W.3d 564 (Tex. Crim. App. 2019) (reversing and remanding) (Fraser II); Fraser v. State, 593 S.W.3d 883 (Tex. App.—Amarillo 2019, pet. ref’d) (Fraser III). Following a plea of not guilty, Appellant, Marian Fraser, was convicted by a jury of

felony murder and sentenced to fifty years’ confinement.2 She challenges her conviction

by the following issues:

(1) The evidence is insufficient to prove she gave the victim diphenhydramine.

(2) The evidence is insufficient to prove administering diphenhydramine to a child is an act clearly dangerous to human life.

(3) The trial court erred in denying her motion to suppress search warrants lacking particularized facts establishing probable cause.

(4) The trial court erred in repeatedly admitting speculative and unproven extraneous offenses.

(5) She suffered egregious harm by a jury charge that failed to require the essential element that an act clearly dangerous to human life be “in furtherance of” the underlying felony.

(6) The jury charge contained other errors which when combined resulted in egregious harm.

(7) She was denied a fair and impartial trial by the trial court’s failure to exercise its discretion for a change of venue due to a prejudice-ridden environment.

(8) Her Sixth Amendment rights were violated by admission of the autopsy findings that changed the manner of death from undetermined to homicide based on invalid testing.

(9) The evidence was insufficient to support felony murder because there was not an act clearly dangerous to human life separate from the act constituting the underlying felony.

(10 ) The jury charge was fundamentally defective by allowing a felony murder conviction based on a single act.

We affirm.3

2 TEX. PENAL CODE ANN. § 19.02(b)(3) (referred to as the felony murder statute).

3 Originally appealed to the Tenth Court of Appeals, this appeal was transferred to this Court by

the Texas Supreme Court pursuant to its docket equalization efforts. TEX. GOV’T CODE ANN. § 73.001. 2 BACKGROUND

For more than two decades, Appellant operated a State licensed daycare center

out of her home in Waco, Texas, and her services were in high demand. She generally

limited her care to twelve infants, all under the age of two years. The infants were kept

on a well-defined daily schedule that included naptime between the hours of 12:00 and

3:00 p.m. and she discouraged parents from interrupting the daily routine.

The four-month-old victim, C.F., began staying at Appellant’s daycare on January

2, 2013. In late January, she was sleeping a lot and developed a cough around mid-

February. Later in February, she had a fever which her mother attributed to routine

immunizations.

On March 4, 2013, Appellant and Sherri Adams were working at the daycare. C.F.

arrived at the daycare at approximately 7:45 a.m. She generally brought her own bottle

because she would not finish it at home, and it was usually given to her between 8:15

and 8:30 a.m. Between 11:15 and 11:30, Appellant gave C.F. a bottle. She was solely

responsible for preparing bottles for the children.

C.F. generally slept in a baby swing during naptime but on that day, Appellant

placed her in a bed because she was moving more. As required by State licensing

standards, she placed C.F. on her back. She checked on the children every fifteen

minutes or so.

Should a conflict exist between precedent of the Tenth Court of Appeals and this Court on any relevant issue, this appeal will be decided in accordance with the precedent of the transferor court . TEX. R. APP. P. 41.3.

3 Around 2:30 p.m. on March 4, Appellant received a phone call from a parent who

wanted to pick up her child early. That child slept in the bed next to C.F. When Appellant

went to get the child, she noticed that C.F. had rolled over and thrown up. She was

unresponsive and not breathing and Appellant began compressions and CPR. She

instructed Adams to call 911. When EMTs arrived, they continued CPR and took C.F. to

the hospital. Appellant rode in the ambulance with C.F and C.F.’s mother was contacted.

C.F. was pronounced dead approximately an hour after arriving at the hospital.

She was the McLennan County Judge’s granddaughter, and her death garnered much

attention. C.F.’s parents initially believed she had died from sudden infant death

syndrome. Her body was sent to a forensic institute in Dallas for an autopsy. A toxicology

report revealed that she had a high level of diphenhydramine in her system when she

died.

Experts testified that diphenhydramine is an antihistamine commonly used as the

active ingredient in over-the-counter medications such as Benadryl and other medications

commonly used to treat allergy and cold symptoms. It can cause sedation and sleepiness

and in excess amounts can affect bodily functions like heartbeat and respiration which

can result in death. It is especially harmful to infants because their underdeveloped livers

are unable to metabolize it and it remains in their system for longer periods of time.

During the investigation, other parents had their children tested and

diphenhydramine was found in varying levels in all of those tested.4 The Childcare

4 The hair follicle test results were admitted in the first trial but were not admitted in the retrial due

to the laboratory and doctor being discredited. The State instead presented extraneous testimony from some of the parents who testified to their children’s ailments which they attributed to exposure to diphenhydramine. The extraneous evidence is discussed infra in issue four. 4 Licensing Department of the Texas Department of Family and Protective Services

requires written authorizations from parents for dispensing over-the-counter medications.

Unfortunately, Appellant usually obtained consent via text messages. When she became

aware of the State licensing regulations, she panicked about not having followed protocol.

The licensing department received an intake of C.F.’s death on the night of her

death and immediately opened an investigation. The administrator for daycare

investigations went to Appellant’s home that evening. The next day, the case was

assigned to a childcare investigator. She interviewed Appellant, Adams, C.F.’s parents,

other parents, and a detective.

The investigator cited Appellant for, among other violations, physical abuse and

neglect and not using good judgment. Thereafter the case was given to licensing

inspectors who made unannounced visits. Appellant was asked to close the daycare

pending the investigation, but she agreed to do so only for a week because other parents

expressed a need for childcare. The State’s investigation revealed that Appellant stored

over-the-counter medications in a cabinet together with some prescription medications.

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